From: DanMcKeel2@aol.com [mailto:DanMcKeel2@aol.com] 

Sent: Saturday, March 17, 2012 12:35 AM 

To: NIOSH Docket Office (CDC) 

Cc: danmckeel2@aol.com

Subject: Docket 140 (GSI) submission 

NIOSH Docket 140 

General Steel Industries 

Attachment <McKeel5ppt2.pdf> 5.3MB 

Dear Docket Office: 

Please accept this PDF file of a Powerpoint presentation I made, in person, at the TBD-6000 work group 

in Cincinnati on March 15, 2012. The topics are germane to revising Appendix BB and consideration of 

SEC-00105. These issues are central to the David Allen/DCAS August 2011 and January 2012 white 

papers dealing with GSI portable sources and Betatron operations, and reviews of these four documents 

by SC&A. It is important that this presentation be processed and posted soon. The TBD-6000 work group 

has scheduled another meeting on 3/28/12 and this presentation also is highly relevant to those 

upcoming deliberations. Thank you for your consideration of my request. 

 -- Dan McKeel 3/16/12 

Daniel W. McKeel, Jr., MD 

GSI SEC-00105 co-petitioner 

Phone: 573-323-8897 

Fax: 573-323-0043 

E-mail: danmckeel2@aol.com

US Mail: P.O. Box 15, Van Buren, MO 63965-0015
GSI Petitioner’s Presentation
 

March 15, 2012, TBD-6000
 

Work Group Meeting
 

- Daniel W. McKeel, Jr., M.D. -
Path Forward For GSI
 

• David Allen white paper: October 20, 2010

disallows use of 80 Curie Co-60 NDT source 

• Proposed new exposure models, based on GSI

information from outside sources, to revise

Appendix BB Rev 0 (June 2007) 

• 13 SC&A Findings on Appendix BB Rev 0 and 

5 of 6 SC&A Findings on SEC-00105 NIOSH

evaluation report October 2008 to be addressed 
Path Forward Work Documents
 

• Dr. Ziemer e-mail outlines ten new NIOSH 

GSI exposure models (5/16/2011) 

• First 4 models in David Allen-DCAS Aug.

2011 white paper on GSI portable sources
 

• Last 6 models in David Allen’s Jan. 2012
 

white paper on GSI Betatron operations
 

• The five (5) SEC issues go unaddressed 
Petitioner Concerns - 1
 

• Old Betatron model is grossly inadequate; Old and

New buildings and x-ray units are not the same
 

• New Betatron model uses 1971 data for 80 curie 

Co-60 source that is not allowed under EEOICPA 

to validate film badge readings from 1964-1966

• OCAS-IG-003 not adhered to: Old Betatron, GSI

owned 10 to 20 curie Ir-192 source, (2) 250 KVP

portable industrial x-ray units doses not defined

• No radon model for GSI extensive underground

campus wide tunnel and conveyor belt networks
 
GSI Ir-192 Source - affidavit 1
 
GSI Ir-192 Source - affidavit 2
 
Dying Man Declaration-1

Iridium-192 GSI Source Iridium-192 GSI Source
 

The attorney son of GSI Radiographer “R.W.” (deceased) 

filed this formal affidavit on November 25, 2006: 

“8. My job duty was to X-ray castings with 

The Betatron. I used 250 KVP Industrial 

Radiographic Equipment and also x-rayed 

castings, using Cobalt 60 and . 

The latter unit was in the Betatron room, 

was mobile and sat on the floor.” 

Iridium 192 Iridium 192

GSIIridium-192 Iridium-192 Affidavit Affidavit #3
 
Dying Man Declaration-2
 

The attorney son of GSI Radiographer “R.W.” (deceased) 

filed this formal affidavit on November 25, 2006: 

“Before I had ever heard of the concept of 

Activation, I explained to my son that after 

the Betatron was turned off after a “shot” 

I could still get a radioactive meter reading 

at the site of the shot. The reading was 

most apparent from the cone of the Betatron 

itself... This was a concern because in 

setting up the shot my back was between the 

cone and casting... one to two ft. from cone.” 
Petitioner Concerns - 2
 

• Modeling of the New Betatron bldg. errs by

including a lead shielded double leaf door 

that GSI Betatron workers state was not 

there in 1964-66 

• DOE/ORNL 1992 and McKeel 2006 photos

show a double leaf NBB door, no lead

shield and show a ribbon roll up door at the

entry of tunnel break area into Bldg. 10 
-
Double Leaf Metal Door (no lead shield) 2006 McKeel Photo
 

LEGEND. View from the Old Betatron railroad track tunnel looking out. 

Photo by Dan McKeel 2006. Double leaf metal door has exposed vertical 

struts that are not covered by lead shields. Workers confirm no lead shield. 
Red Ribbon Roll Up Door at Entry of New Betatron Tunnel

2006 Dan McKeel Photo
 

Workers testify this type of door at Old & New Betatrons 1964-1966
 
Allis-Chalmers Manual Rollup Door
 

Allis-Chalmers BETATRON Building 

Testimony 3/13/12 that this ribbon steel 

door was just recently replaced this year 
Concern: No Pre-June/July 1962

Bldg. 6 Ra-226 SC&A Modeling
 
Bldg. 6 Radiograph Room 1957
 

• A new GSI map obtained by John Ramspott

conclusively proves the GSI bldg. 6 inner

radiography concrete block structure existed 

on January 29, 1957 

• Worker testimony establishes that Ra-226

sources were used in this facility for NDT

inspection of RR trucks “even earlier than

the AEC work,” which means prior to 1953 
The GSI Building 6 Radiograph Room Map 1/29/57
 

CASTINGS CORP. 

(tttA.'41l'P ~ITV,U,.\. 

GENErRAL ORA'A\NG · 

OF 

GRAN\TE C,lT:Yr LANT. 
Concern About Konneker 1962 Bldg. 6 Survey 

LEGEND. Gondola/cab far left hangs below 

crane. Catwalk above and hanging hook 

(arrow) blocks measured Co-60 radiation. 

NCC radiologic survey NCC radiologic survey

Radiographic Facility Radiographic Facility

Left: Mass of the 

Bldg. 6 crane could

attenuate Co-60 dose 

to crane operator and

Konneker measured 

dose on structures 

above the crane. 

1. Allen 1971 Co-60/MCNPx 1.8 vs 0.2 mR/hr GSI

 Betatron data = a 9-fold significant difference. 

2. Question: Why did NIOSH or SC&A not model

 the Bldg. 6 Co-60 source NCC data w/ MCNPx? 
GSI workers dispute 24” walls and
 

Steel shields prior to and after 1962
 
Underestimated Exposure Paths
 

In the area between Betatron buildings. 

Bottom. Walkways 

near Bldg. 6 Radiograph Room were 

used by many GSI 

workers on way to 

and from foundry. 

Estimated 300 GSI 

employees worked 

in this area. 

Left. Photo of the GSI New 

Betatron building and the 

crowded area between it 

and the Old Betatron Bldg. 

This area was busy. A main 

road used by most workers 

ran between the buildings. 

Many unbadged workers 
Road & Track Traffic Between Betatrons
 

LEGEND. Old & Future New Betatron buildings 1957 are spaced 300 feet apart in busy area 

Radiation fields extend 100 feet away from buildings based on OBB Sign 

I •• if 

..01! 

,.--- , j / • I 

/ / ul , ./ 

•J 
Landauer Control Room Badges
 

• NIOSH and SC&A state Landauer GSI film
 

badge reports include data on 114 “control
 

room badges” that Allen uses to limit doses
 

• Two GSI badge handlers refute this fact 

• A New Betatron building drawing shows

two locations where film badges were

racked away from the console control room. 
Badged Betatron “Employees”
 (begin quote) 

(end quote) 

This affidavit was recently obtained from the first clerk 

who handled GSI film badges on startup of the New 

Betatron operation in 1964. It is clear that not only the 

Betatron operators and isotope workers were badged. 

Petitioner Concerns - Badges
 

• A new affidavit attests that GSI badge

handlers sometimes destroyed film badges

they believed to be spurious. The affiant

believes this fact casts doubt on the validity

of the entire GSI film badge program 

• Further doubt is cast because radiographers

wore badges part time, and GSI submitted

control room badges that did not exist. 
Pedigree of GSI Badge Data is

Seriously Flawed & Incomplete
 
2008 & 2012 Models Disagree
 
Conclusion & Summary
 

• NIOSH and SC&A 2012 MCNPx models disagree

with each other and with film badge data and are

based on many erroneous assumptions

• Compared to 2007 and 2008 model data, SC&A

Betatron operator doses show a 90% decrease 90% decrease

while Layout doses sharply increase increase compared to

all NIOSH estimates for non-Betatron workers 

• The TBD-6000 work group should vote today to

recommend approving SEC-105 to the full Board 
Petitioner Contact Information Petitioner Contact Information
 

Respectfully submitted

March 15, 2012

Daniel W. McKeel, Jr., M.D.,

Phone: 573-323-8897 

Fax: 573-323-0043 

E-mail: danmckeel2@aol.com